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MLO e-signature on Initial 1003

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I recently had a debate with a former colleague regarding the Mortgage Loan Originator (MLO) e-signature on the initial 1003 sent to the borrower for initial disclosure purposes. This colleague stated that the MLO had given consent/permission to the processor to complete the MLO's e-signature due to the expeditious nature of the loan in question as the MLO would not be able to get to it for a few days. Keep in mind that it was only the e-signature of the MLO on the initial 1003, not the borrower. This individual was not being fired or resigning as they would be returning within 2-3 days but the loan needed to be moved into underwriting. I was not to sure about this. Does this constitute a violation, or is it considered fraud?

I am not aware that a 1003 has to include an MLO signature, just their NMLS number. Any signature requirements would be imposed by Bank or Investor requirements.

First published on 04/19/2020

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